Consultation analysis: electrofishing for razor clams in
Scotland

1. A total of 104 responses were received;
74% from individuals and 26% from organisations.
There were no campaign responses; however a few duplicate responses
were received.

2. Counting duplicate replies once, respondents were divided
into one of five categories based on information provided on their
Respondent Information Form.

Respondent category

Number

Percentage

Individual

75

74%

Commercial business

5

5%

Non-profit organisation (fishing
industry)

6

6%

Non-profit organisation (non-fishing
industry)

11

11%

Public sector

4

4%

Total

101

100%

3. Two non-profit organisation (non-fishing industry)
respondents endorsed the response from Scottish Environment
LINK
- as well as providing their own organisational response (which was
worded differently, but tended to express the same points). River
Ayr District Salmon Fishery Board endorsed the response from
Ayrshire Rivers Trust but did not provide further comment.

respondents who felt further scientific investigation is
required before the electrofishing method can be properly
evaluated; and,

respondents who did not express a clear opinion.

7. The majority of individual respondents were not in favour of
permitting electrofishing. Commercial businesses and non-profit
organisations (fishing industry) tended to be supportive of
electrofishing, whilst the majority of non-profit organisations
(non-fishing industry) welcomed further research (see graph
below).

Responses by group: Should electrofishing be a permitted
method of catching razor clams?

Respondents opposed/broadly unsupportive of permitting
electrofishing

8. With duplicate responses excluded, 50% of total responses
were opposed/broadly unsupportive of catching razor clams by
electrofishing. 90% of responses in this group were from
individuals with the remaining 10% from non-profit organisations
(non-fishing industry).

9. The majority (64%) of respondents in this group said they
have concerns that electrofishing has a detrimental impact on the
ecosystem, in particular on the benthic community or at different
life stages of species. Anglers cited concerns about the effect of
electrofishing on species such as tope and bass. Respondents felt
that the 2014 study by Marine Scotland Science
[1] was light on parameters considered.

10. Half of all respondents in this group expressed concern
about the efficiency of the electrofishing method and the
sustainability of local razor clam beds. Respondents said that they
did not think current razor clam harvesting rates are sustainable.
Many felt the efficiency of the method warranted its continued
prohibition.

"There are too many that look at these as a way of making large
and quick profit, with no thought about what the sustained impact
is on the health of our ocean"

11. 46% of respondents in this group expressed concern about the
current and/or future enforcement of the razor clam fishery. Many
questioned how electrofishing would be monitored and controlled if
it were legalised.

"If enforcing a ban on electrofishing of razor clams is
difficult to enforce, will regulation of razor clam fishing be
improved by legalising electrofishing?"

12. 16% of respondents in this group documented concerns with
current illegal electrofishing practices in Luce Bay. A few other
responses cited concerns in other areas including the Clyde,
Orkney, Western Isles and Arran.

13. With duplicate responses removed, 37% of total responses
received were supportive/broadly supportive of permitting
electrofishing for razor clams. The group comprised individuals
70%, commercial business 14%, non-profit organisations (fishing
industry) 11%, public sector 5%.

14. All commercial businesses (5) that responded to the
consultation were in favour of permitting electrofishing for razor
clams.

15. At least 58% of the individuals in this group referred to
first-hand experience of electrofishing for razor clams.

16. 68% of respondents in this group stated that they thought
electrofishing should be permitted because it is a more benign
fishing method compared to other legal methods e.g. dredging.
Respondents highlighted the selectivity of the electrofishing
method and improved quality of the catch due to reduced physical
damage during harvesting.

"It would seem particularly perverse to apply legal and costly
sanctions against people trying to earn a living by the most
environmentally friendly means while, permitting and promoting more
environmentally intrusive forms of fishing because the most
damaging method is less effective at catching."

17. 43% of all respondents in this group highlighted the
benefits they thought a razor clam fishery could bring, in
particular economic and employment benefits to rural, fragile
communities and the inshore fleet.

"With good domestic and export markets for razor clams the
development of a small scale, well controlled, licensed fishery
would be beneficial to fishing communities through the
islands"

18. 35% of respondents in this group felt that if electrofishing
were to be permitted it could encourage a more cooperative approach
from the sector by bringing operators in from the dark. This in
turn could reduce the 'cowboys' currently involved in the fishery
and improve issues such as health and safety.

19. Although the consultation was not about how a razor clam
electrofishery might be managed, many of these responses
acknowledged that any such fishery would need to be well regulated
to ensure it is sustainable, safe and well-managed.

20. A couple of responses referred to the minimum landing size
for razor clams, implying that it should be >100mm. There was a
suggestion that Inshore Fishery Groups might be best placed to
develop and oversee Management Plans of the razor clam fishery.

Respondents who consider further research is required in
order to evaluate electrofishing

21. With duplicate responses removed, 11% of total responses
received concluded that more extensive scientific research was
required before electrofishing could be properly evaluated,
including 36% individuals, 9% non-profit organisation (fishing
industry) and 55% non-profit organisation (non-fishing
industry).

Key themes from responses that requested further scientific
research

22. There is considerable overlap between the key themes from
this group and the key themes that emerged from the group of
responses opposed to permitting electrofishing (page 3). However,
respondents in this group accept that there is credible evidence
for considering a new approach to electrofishing because scientific
research
[1] suggests that electrofishing for razor clams causes fewer
negative environmental impacts, when compared to other methods that
are legal.

23. Whilst acknowledging the research findings, these responses
encouraged a cautious approach and made recommendations on future
scientific requirements i.e.:

assessments of razor clam stock size and distribution;

research on longer term effects of electrofishing on target
and non-target species;

evidence gathering on suitable minimum landing sizes;

establish small-scale pilot studies where electrofishing as a
commercial fishery is monitored; and,

Appropriate Assessment as part of the Habitats Regulations
Appraisal process.